Privacy Policy for Smart Trade
Eective Date: November 6, 2025
This Privacy Policy explains how Centre for Innovation in Technology (Zimbabwe) ("we,"
"our," or "us") collects, uses, protects, and discloses information and data when you use the
Smart Trade mobile application (the "Service").
1. Data Controller Information
Application Name: Smart Trade
Developer/Company Name: Centre for Innovation in Technology (Zimbabwe)
Contact Email for Privacy Maers: info@citzim.co.zw
2. Information We Collect
We collect information in the following categories to provide and improve the Service:
2.1 Information Provided by You
When you create an account, verify your identity, or use the trading services, you provide us
with:
● Identity Data: Name, email address, phone number, and physical address.
● Account Credentials: Encrypted password and security questions.
● Verication Data (KYC): Copies of government-issued identication (e.g., ID card,
passport), and/or photographic evidence for identity verication.
● Financial Data: Bank account details for fund transfers, trading transaction history, and
porolio information.
● Communication Data: Information you provide when contacting customer support or
communicating with us.
●
2.2 Information Collected Automatically
When you access the Service, we automatically collect certain usage data:
● Device and Usage Data: Information about how you access and use the Service,
including your IP address, operating system version, device model, time zone, mobile
network information, and crash reports.
● Location Data: [IF APPLICABLE, STATE THIS:] General location data (e.g., city/country)
inferred from your IP address.
3. How We Use Your Information
We use the collected information for the following purposes:
● Service Provision: To create, maintain, and secure your account; process your trading
orders and fund deposits/withdrawals; and provide customer support.
● Security & Compliance: To verify your identity (KYC/AML checks), detect and prevent
fraudulent activities, and comply with all applicable legal and regulatory obligations.
● Analytics and Improvement: To monitor and analyze usage, performance, and
functionality of the Service, and to improve our features and oerings.
● Communication: To send you service updates, security alerts, and support messages.
4. Disclosure and Sharing of Your Information
We may share your information with the following parties:
● With Third-Party Service Providers: We use third-party companies to facilitate our
Service, such as payment processors, market data providers, cloud hosting services
(e.g., AWS, Google Cloud), and analytics providers (e.g., Google Firebase). These
providers only have access to the minimum data necessary to perform their functions
on our behalf.
● For Business Transfers: If we are involved in a merger, acquisition, or sale of assets,
your personal data may be transferred, provided the new entity adheres to this Privacy
Policy.
● For Legal Reasons: If required by law, subpoena, or governmental request, we may
disclose your information to protect our rights, your safety, or the safety of others, or to
investigate fraud.
5. Data Security
The security of your data is paramount. We implement industry-standard security measures,
including encryption and multi-factor authentication, to protect against unauthorized access,
disclosure, alteration, or destruction of data. However, please remember that no method of
transmission over the Internet or method of electronic storage is 100% secure.
6. Data Retention
We will retain your Personal Data only for as long as is necessary for the purposes set out in
this Privacy Policy, including retaining data to comply with our legal obligations (e.g., nancial
regulatory requirements) and to resolve disputes.
7. Children's Privacy
The Service is not intended for use by individuals under the age of 18. We do not knowingly
collect personally identiable information from children under 13. If you become aware that a
child has provided us with Personal Data, please contact us immediately, and we will take
steps to remove that information.
8. Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by
posting the new Privacy Policy in the app and updating the "Eective Date" at the top of this
policy. You are advised to review this Privacy Policy periodically for any changes.